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Body fat % determines how toned you are. Bodybuilders will go so far as to do fasted morning cardio and carb depletion workouts. However, on your way to slimming down you can build substantial amounts of muscle that will help your "tone" later on down the road.

I encourage people who are overweight to exercise regularly because once their body does lose the weight and they become a little more pleased with their body, then you will already have the muscle to take it to the next step

I think it's possible to tone up, and the workouts to tone will help with weight loss. I am thick and have very toned legs with fat on them. My muscle definition isn't that of a fit or "skinny" girl, but when I flex you can really see the muscles.